17/10/2013 - Russia has yet to address key provisions of the OECD Anti-Bribery Convention, which entered into force in Russia in April 2012. It has not yet fully implemented recommendations for strengthening its framework for combating foreign bribery and should be more proactive in detecting, investigating and prosecuting foreign bribery cases.

Expand the scope of its foreign bribery offence so that it applies to all of the cases covered by the OECD Anti-Bribery Convention;

Further strengthen its recently instituted framework for holding companies liable for foreign bribery;

Take steps across law enforcement and related agencies to implement a proactive approach to detecting, investigating and prosecuting foreign bribery offences and related accounting offences;

Take measures to allow for the seizure and confiscation of the bribe and its proceeds in proceedings against natural and legal persons and improve coordination and accountability among law enforcement authorities; and,

The Working Group also highlighted positive aspects of Russia's efforts to fight foreign bribery, including the explicit disallowance of the tax deductibility of bribes to foreign public officials. Russia also recently passed a statutory requirement for companies in Russia to have anti-corruption measures in place and has assisted other Parties to the Anti-Bribery Convention in their investigations of foreign bribery.

Russia will make a special written follow-up report to the Working Group on its actions to implement the Working Group's recommendations before the end of 2014.

The report, available here, lists all the recommendations of the Working Group on pages 90-98, and includes an overview of recent enforcement actions and specific legal and policy features in Russia for combating the bribery of foreign public officials.